O'Leary v. Humana Insurance Company

CourtDistrict Court, E.D. Wisconsin
DecidedNovember 30, 2020
Docket1:17-cv-01774
StatusUnknown

This text of O'Leary v. Humana Insurance Company (O'Leary v. Humana Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Leary v. Humana Insurance Company, (E.D. Wis. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

CAROLYN J. O’LEARY, individually and on behalf of all others similarly situated,

Plaintiffs,

v. Case No. 17-C-1774

HUMANA INSURANCE COMPANY, et al.,

Defendants.

DECISION AND ORDER DENYING MOTION TO DECERTIFY

Plaintiff Carolyn J. O’Leary, individually and on behalf of all others similarly situated, commenced this action under the Fair Labor Standards Act, 29 U.S.C. § 201 et seq. (FLSA), against Defendants Humana Insurance Company and Humana Inc. (collectively, Humana) on December 20, 2017. On June 14, 2018, the court approved the parties’ stipulation to conditionally certify this collective action. Dkt. No. 23. This matter comes before the court on Humana’s motion to decertify. For the following reasons, the motion will be denied. BACKGROUND Plaintiffs allege that Humana operated a willful scheme to deprive its clinical nurse advisors and other similarly-situated employees of overtime compensation by classifying them as exempt under the FLSA and paying them a straight salary with no overtime. On June 12, 2018, the parties stipulated to conditionally certify a collective action pursuant to Section 16(b) of the FLSA. Dkt. No. 22. The court approved the stipulation and ordered that a collective action be conditionally certified under 29 U.S.C. § 216(b) to include: All persons who were classified as exempt under the FLSA and worked as clinical nurse advisors for Defendants in the roles of Clinical Intake, Clinical Claims Clinical—Senior Products utilization management nurses, at any time within the three years prior to the date the Court approves this Stipulation.

Dkt. No. 23. In its motion to decertify the conditionally-certified collective action, Humana describes the job duties of the five categories of employees identified in the collective action: (1) Acute Case Mangers, (2) Clinical Intake Nurses, (3) Market Clinical Senior Products Nurses (which Humana further divides into Home Health Team Nurses, On-Site Nurses, and Telephonic Review Nurses), (4) Clinical Claims Review Nurses, and (5) Clinical Claims Review–DME Nurses. Acute Case Managers provide “guidance along the healthcare continuum” by identifying the healthcare resources “most consistent” with the needs of Humana’s members, including deciding whether to approve admission or a stay at a healthcare facility. Dkt. No. 203 at 3. Clinical Intake Nurses review clinical data to determine whether requested services are covered by a member’s plan and identify the healthcare resources “most consistent” with a member’s policy and needs. Id. at 5. Humana asserts that Market Clinical Senior Products Nurses can be further separated into three categories: Home Health Team Nurses, On-Site Nurses, and Telephonic Review Nurses. Home Health Team Nurses use guidelines to decide if a member is authorized for home health care visits. Id. at 6. On-Site Nurses work from their home offices but also meet in-person with patients at facilities to assess patient needs and develop post-discharge plans. Id. at 6–7. Telephonic Review Nurses review pending cases, perform concurrent reviews, and are tasked with

follow-up reviews to assess patient progress and discharge plans. Id. at 7. Clinical Claims Review Nurses use their clinical knowledge to complete case reviews to evaluate services using medical records of procedures that already occurred. They also perform PPO reviews to determine whether certain outpatient procedures, like physical therapy and x-rays, are covered under Humana’s Medicare supplement. Id. at 7–8. Nurses in the Clinical Claims Review–DME (Durable Medical Equipment) category review requests for durable medical equipment, using their clinical experience and nursing knowledge to do so. Id. at 9. LEGAL STANDARD The FLSA permits collective actions “against any employer . . . by any one or more

employees for and on behalf of himself or themselves and other employees similarly situated.” 29 U.S.C. § 216(b). Employees or former employees must give their consent in writing to become a party to a collective action brought pursuant to § 216(b). Therefore, unlike a typical class action suit under Rule 23, where unwilling parties must “opt out” of the class, the FLSA requires employees to “opt in” to the class. Woods v. N.Y. Life Ins. Co., 686 F.2d 578, 579–80 (7th Cir. 1982). The second step in an FLSA collective action—generally upon a defendant’s motion for decertification—involves determining whether plaintiffs who have opted into the lawsuit are, in fact, similarly situated. Brabazon v. Aurora Health Care, Inc., No. 10-C-714, 2011 WL 1131097, at *2 (E.D. Wis. Mar. 28, 2011). At this stage, the court assesses whether continuing as a collective

action will provide efficient resolution in one proceeding of common issues of law and fact. See Hoffmann-La Roche v. Sperling, 493 U.S. 165, 170 (1989). On a motion to decertify the conditional collective action, the plaintiff retains the burden of demonstrating that certification is appropriate. Ellis v. Elgin Riverboat Resort, 217 F.R.D. 415, 419 (N.D. Ill. 2003); see also Long v. Epic Sys. Corp., No. 15-CV-81-BBC, 2016 WL 4625497, at *4 (W.D. Wis. Sept. 6, 2016) (citation omitted). In determining whether parties are “similarly situated,” the court considers certain factors, including (1) any disparate factual and employment settings of the individual plaintiffs, (2) the various individualized defenses available to the defendant, and (3) fairness and procedural considerations. Thiessen v. Gen. Elec. Capital Corp., 267 F.3d 1095, 1102–03 (10th Cir. 2001) (cited approvingly in Espenscheid v. DirectStat USA, LLC, 705 F.3d 770, 771–72 (7th Cir. 2013)). ANALYSIS A. Factual and Employment Settings of the Individual Plaintiffs

Humana argues that the disparate factual and employment settings among Plaintiffs require decertification. It asserts that the five different roles that Plaintiffs could hold in its organization had disparate tasks, duties, productivity standards, and qualifications, among other criteria, that distinguish Plaintiffs. Humana claims that, because the factual and employment settings are disparate, they would be required to examine each of the over 200 Plaintiffs as witnesses at trial. Plaintiffs submit they have met their burden to retain certification of the collective action. They argue that Plaintiffs were all Clinical Nurse Advisors (also referred to as Clinical Advisors) who shared the same primary job in utilization management (UM Nurses) and were classified as exempt under the FLSA. Dkt. No. 211 at 6. Plaintiffs dispute that the five categories Humana identified for the UM Nurses are factually disparate for purposes of proceeding as a collective

action. Plaintiffs argue that the descriptions rely on Humana’s own outdated job descriptions and, essentially, all describe similar utilization management tasks that these employees performed. They contend that all of the UM Nurses followed the “same core steps” in their work irrespective of the various job titles. Id. at 8.

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O'Leary v. Humana Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oleary-v-humana-insurance-company-wied-2020.